Document n9L7vyGXmm02wNM7bwBjzbBMw

/ To: RV- Casper INDUSTRIES iNTER-OFFICE CORRESPONDENCE Date: July 22, 1976 From: Z. G. Bell, Jr. Location: 10 West Subject: Mock OSHA Inspection Asbestos A Mock OSHA Inspection was made on July 14, 1976 beginning at 11:00 a.m. and completed at 12:45 p.m. Messrs. T. Hatfield, E. J. Tullier, D. Savoy and you accompanied myself and P. J. Snyder on this inspection. The following items are alleged violations of 29 CFR 1910.1001 Asbestos Standard, 1910.134 Respiratory Protection and 1910.22 General Requirements (OSHA). ITEM NUMBER STANDARD REGULATION OR SECTION ALLEGEDLY VIOLATED DESCRIPTION OF ALLEGED VIOLATION SUGGESTED DATE FOR CORRECTION OF ALLEGED VIOLATION 29 CFR 1910.1001 (C)(2)(i) and (2)(ii) (2) Work practices--(1) Wet methods. Insolar as practicable, asbestos shall be handled, mixed, applied, removed, cut scored, or otherwise worked In a v,-et state sufficient to prevent the emission ol airborne libers in excess of the ex posure limits prescribed in paragraph <b) of this section, unless the usefulness of the product would be diminished thereby. (ID Particular products and opera tions. No asbestos cement, mortar, coat ing, grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being cither wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed in paragraph (b) of this section. F ON M 503- A REV 6-1-70 Cell Removal Area (1) Asbestos rope removed from container without methods specified to reduce emissions. August 11, 1976 (2) Asbestos rope cutting without dust suppression techniques being used. August 11, 1976 (3) Asbestos rope cutting in bridge between K302 and K303 without measures to control airborne emissions. August 11, 1976 Fluffing Area (4) Asbestos removed from bags by puncturing for quality control and bags not resealed. July 15, 1976 (5) Torn bags of asbestos not properly resealed in storage area. July 15, 1976 (6) Improperly maintained enclosure for fluffing - rubber flaps missing improperly maintained. Cell Auxiliary Bay Area July 21 , 1976 T BeT0000079 | (7) Asbestos transferred from container August 4, 1976 to drums without control measures to suppress airborne emissions. R. C,as^er -? July 22, 1976 ITEM NUMBER STANDARD REGULATION OR SECTION ALLEGEDLY VIOLATED DESCRIPTION OF ALLEGED VIOLATION SUGGESTED DATE FOR CORRECTION OF ALLEGED VIOLATION 2. (C)(l)(iii) and (C)(2)(iii) (8) Hand operated power tool (chipper) used to remove (Hi) Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers} In excess of the exposure limits pre scribed m paragraph (b) of this section, such as, but not limited to, saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems in accordance with subdivision (11) of this subparagraph. (9) asbestos from cell without local exhaust ventilation. Worker operating power tool (7) without respiratory protection. (ill) Spraying, demolition, or removal. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or insulated with asbestos, and in the removal or demolition of asbestos in sulation or coverings shall be provided with respiratory equipment in accord ance with paragraph (d)(2)(iii) of this section and with special clothing in ac cordance with paragraph (d) (3) of this section. August 18, 1976 July 15, 1976 3. (d)(2)(iv)(a); ANSI Z88.2-1969 (3.5.6) and 1910.134(b)(6) (10) (lv) Establishment of a respirator pro gram. (a) The employer shall establish (11) a respirator program in accordance with the requirements of the American Na tional Standards Practices for Respira tory Protection. ANSI Z88.2-1969, which (12) is incorporated by reference herein. '5.6 Respirators shall be stored in a conlient, clean, and sanitary location. See 8.5. Replacement and respirators improperly stored in cell renewal area (east wall). Improper storage of Confo-II respirator near lead pots. Single use air purifying respirators not properly protected while not in use (fluffing area and slurry tank area). (8) Respirr.tors shall be stored in a convenient, clean, and sanitary location New respirators stored in tool cabinet unprotected. July 15, 1976 July 15, 1976 July 15, 1976 July 15, 1976 1 3B 0000030 | R. Caspar -3- July 22, 1976 ITEM NUMBER STANDARD REGULATION OR SECTION ALLEGEDLY VIOLATED DESCRIPTION OF ALLEGED VIOLATION 4. 1910.134 (b)(7) (14) Respirator (Confo cartridge (7) Respirators used routinely shall be inspected during cleaning. Worn or deteriorated parts shall be replaced. Res pirators for emergency use such as selfcontained devices shall be thoroughly inspected at least once a month and after each use. type) not cleaned and deteriorated on west wall bench cell renewal area. 5. 1910.134 (b)(9) <9) There shall be regular inspection and evaluation to determine the con tinued effectiveness of the program. (15) Excessive number of discarded respirators located at non-designated collection points. Inadequate regular inspections. 6. 1910.134 (e)(5) (5) For safe use of any respirator, it is essential that the user be properly In structed In its selection, use, and main tenance. Both supervisors and workers shall be so Instructed by competent per sons. Training shall provide the men an opportunity to handle the respirator, have it fitted properly, test its face-pieceto-face seal, wear it in normal air for a long familiarity period, and, finally, to wear it in a test atmosphere. (16) Improper use of Confo-II mask by lead pot operator (bottom strap not used for proper facial fit). 7. 1910.1001 (d)(2) (iv)(a) and 1910.134 (b)(1) (lv) Establishment ot a respirator pro gram. (a) The employer shall establish a respirator program in accordance with the requirements of the American Na tional Standards Practices for Respira tory Protection, ANSI Z88.2-1969, which is incorporated by reference herein. (17) No written respiratory protection program specific to the asbestos cell renewal area available. (b) ReQuircments for a minhnal acccptcbZfi propT'CTJi. (1) Written standard aerating procedures governing the se lection and use of respirators shall he established. SUGGESTED DATE FOR CORRECTION OF ALLEGED VIOLATION July 15, 1976 July 15, 1976 July 15, 1976 August 11, 1976 i t I BB 0000081 { l R. Casper -4- JuTy 22, 1976 HEM NUMBER STANDARD REGULATION OR SECTION ALLEGEDLY VIOLATED DESCRIPTION OF ALLEGED VIOLATION SUGGESTED DATE FOR CORRECTION OF ALLEGED VIOLATION 8. (d)(3) (3) Special clothing: The employer shall provide, and require the use of, spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any emPloyee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. (18) Employee using air hose to cell bottom without the use of proper clothing. July 16, 1976 9. 1910.1001 (d)(4)(H) (11) Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes. (19) No provision for clothes lockers or containers for special protective garments - garments were hung randomly in work area. August 11, 1976 1(^ 1910.1001 (f)(1) (f) Monitoring--(1) Initial determi nations. Within 6 months of the publi cation of this section, every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way as to determine whether every employee's exposure to asbestos fibers is below the limits pre scribed in paragraph (b) of this sec tion. if the limits are exceeded, the em ployer shall immediately undertake a compliance program in accordance with paragraph (c) of this section. 11. (f)(2)(H) til) Sampling frequency and patterns. After the initial determinations required by subparagraph il) of this paragraph, samples shall be of such frequency and pattern as lo represent with reasonable accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos nay reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section. (20) Initial monitoring to determine every employee's exposure not accomplished within the six months specified. Immediate Program (21) Last monitoring data collection January 9, 1976 which exceeds interval greater than six months. Immediate Program ( bb 0000082 I R. Casper -5- ITEM NUMBER STANDARD REGULATION OR SECTION ALLEGEDLY VIOLATED DESCRIPTION OF ALLEGED VIOLATION 12. (f)(3)(i) and (f)(3)(H) (3) Environmental monitoring--(i) samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8hour time-weighted average airborne concentrations and of the ceiling con centrations of asbestos fibers. lii) Sampling frequency and patterns. After the initial determinations required by subparagraph U> of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. In no case shall sampling be at intervals greater than 6 months for ei^^oyees whose exposures to asbestos n^Breasonably be foreseen to exceed t^^cposure limits prescribed in para graph (b) of this section. 13. 1910.1001 (g)(1)(i) (g) Caution signs and labels. (1) Cau tion signs, (i) Posting. Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed in paragraph (b) of this section. Signs shall be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps be fore entering the area marked by the si ms. Signs shall be posted at all ap proaches to areas containing excessive concentrations of airborne asbestos fibers. (22) Insufficient environmental monitoring of areas which are representative of airborne concentrations which may reach the breathing zone of employees. (23) Entrances into areas where asbestos is used or stored are not properly posted with signs as required (fluffing, cell renewal and storage areas). July 22, 1376 SUGGESTED DATE FOR CORRECTION OF ALLEGED VIOLATION Immediate Program August 11, 1976 ! QB 00Q003_^ R. Casper -6- July 22, 1976 ITEM NUMBER STANDARD REGULATION OR SECTION ALLEGEDLY VIOLATED DESCRIPTION OF ALLEGED VIOLATION SUGGESTED DATE FOR CORRECTION OF ALLEGED VIOLATION 14. (gj(I )(ii) end (g)(z)(i) (ii) Sion specifications. The warning signs required by subdivision (i) ot this subparagraph shall conform to the re quirements of 20" x 14" vertical format signs specified in 5 1910.145(d)(4), and to this subdivision. The signs shall dis play the following legend in the lower panel, with letter sizes and styles of a visibility at least equal to that specified in this subdivision. (2) Caution labels--(1) Labeling. Cau tion labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that d^^ig any reasonably foreseeable use, J^Blng. storage, disposal, processing, or fi^^xntation. no airborne concentra tions of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. 15. (g)(2)(ii) (ii) Label specifications. The caution labels required by subdivision (i) of this subparagraph shall be printed In letters of sufficient size and contrast as to be readily visible and legible. The label *hnn state: Caution Contains Asbestos Fiber* Avoid Creating Dust Brosthing Asbestos Dust May Cause Serious Bodily Harm (24) (25) Signs in areas improper legend. No label on waste container for asbestos (fluffing area). | 1 (26) Five fiber drums not labeled as required (rear storage on pallets. August 11, 1976 July 15, 1976 July 15, 1976 (27) Rope storage container not properly labeled as required. (Bridge between K302 and K303). (28) Waste recepticle for asbestos not properly labeled (Bridge between K.302 and K303). July 15, 1976 July 15, 1976 16. (g)(l )(ii) - See #14. 17. (g)(2)(i) - See #14. (g) (2)(ii) - See #15. (29) Improper signs used to designate asbestos area in cell development area (K304?). (30) Asbestos rope in unmarked and labeled cardboard box near mastic and lead pots. (31) Three trash cans in cell repair area containing asbestos rope not properly labeled. 1 July 21, 1976 July 15, 1976 July 15, 1976 7"bu"0D00084 | R. Casper -7- July 22, 1976 ITEM NUMBER STANDARD REGULATION OR SECTION ALLEGEDLY VIOLATED DESCRIPTION OF ALLEGED VIOLATION SUGGESTED DATE FOR CORRECTION OF ALLEGED VIOLATION (g)(2)(ii) - Cont'd (32) Cabinet containing asbestos rope in K304 north wall not labeled. (33) Trash cans in cell renewal area improperly labeled. (34) Asbestos rope used as plug for solvent can in cabinet not properly labeled. (35) Waste can in cell renewal area damaged so that lid could not be properly positioned, label not legible. July 15, 1976 July 15, 1976 July 15, 1976 July 16, 1976 19. 1910.1001 (h)(1) and 1910.22 (a)(1 and 2) (h) Housekeeping--(i) Cleaning. All external surfaces in any place of employ ment shall be maintained free of accu mulations of asbestos fibers if, with their dispersion, there would be an excessive concentration. (a) Housekeeping. (1) All places of employment, passageways, storerooms, and service rooms shall be kept clean and orderly and in a sanitary condition. (2) The floor of every workroom shall be maintained in a clean and, so far as possible, a dry condition. Where wet proc esses are used, drainage shall be main tained, and false floors, platforms, mats, or other dry standing places should be provided where practicable. (36) Accumulation of dry asbestos on floor in vacuum pump area under cell renewal area. (37) Poor Drainage in fluffing area asbestos storage. 20. 1910.1001 (h)(2) (2) Waste disposal. Asbestos waste, ..-rap, debns, bags, containers, equip ment. ana ssoestos-eontarnlnated cloth ing, consigned for disposal, which may produce in any reasonably foreseeable use, handling, storage, processing, dis posal, or transportation airborne concen trations of asbestos fibers m excess of the exposure limit; prescribed In paragraph (b) of this seci.cn shad be collected and disposed of Li se.-.e.-i impermeable bags, other closed, impermeable containers. (38) Asbestos on floor in cell repair area. (39) Asbestos rope found on top of cabinet in cell room east wal 1. July 16, 1976 July 15, 1976 July 15, 1976 July 15, 1976 \ [i j bB 0000085 R. Casper -8- July 22, 1976 A review of 1910.1001 paragraph U) medical surveillance revealed no alleged violations. It is further submitted that many of the above alleged violations could be contested provided there were sufficient monitoring to demonstrate that the permissible exposure limits were not exceeded. The procedures developed by the plant in the event of an OSHA inspector visits Lake Charles went satisfactorily. Zeb G. Bell, Jr. /elm cc: F. C. Dehn J. M. Davis/D. Savoy J. R. Farst H. M. Finneran L. B. Grant, M.D. F. Ludden/H. B. Lovejoy, M.D. . ~F7 J.' Snyder" ' ~~w T. Taylor E. J. Tullier | Da 0000086 |